S. 92C : Transfer pricing-Arm’s length price-Payment to intra-group services and not stewardship activity-ALP determination was not adjudicated-No ground was raised by the revenue.

S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-Not produced relevant information of the Foreign AEs-Assessee itself is to be treated as the tested party-When the capacity utilization figures of the comparable are not available, ALP can be determined with gross profit margins only qua raw material cost to the exclusion of direct expenses-Turnover filter-Adjustment to be made at entry level only to the value of international transactions. [R. 10B(1)(e)]

S. 92C : Transfer pricing-Arm’s length price-TP adjustments should be restricted to the AE transactions only-Reversal of provision for write back-Matter remanded-VAT refund-Non operating and ice versa-Miscellaneous income-Can not be considered as operating income. [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Recharacterization of the transaction of debt in to equity is not approved-Bench marking of interest payment to AES at 13. 75 % matter remanded-Additional ground on Education cess was allowed. [S. 94B]

S. 92C : Transfer pricing-Arm’s length price-Interest on outstanding receivables-Adjustment is not warranted if pricing/profitability of assessee is more than working capital adjusted margin of comparables companies.

S. 92C : Transfer pricing-Arm’s length price-Assembling of products and sold to customers-TPO was justified in rejecting the RPM and adopting TNMM as the most appropriate method. [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Operating revenue expenses incurred-Order set aside-TP adjustment are only in respect of international transactions and not entry level transactions. [S. 92]

S. 92C : Transfer pricing-Arm’s length price-Customs duty paid-Adjustment is not warranted-Selection of comparable-BEML being a Government company cannot be included in the list of comparables. [R. 10B(1)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-BEM being a Government company-Not includible in the list of comparables-99.65 per cent of the manufacturing activity of JCB Ltd is functionally similar-Included in the comparables. [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Working Capital adjustment Advances to suppliers and advances from customers are integral part of working capital adjustment and cannot be excluded in computing working capital adjustment. [R. 10B]